Abstract
BACKGROUND:
Professional medical associations (PMAs) play a crucial role in providing accredited continuing medical education (CME) to physicians. Funding from the pharmaceutical industry may lead to biases in CME.
OBJECTIVE:
This study examines publicly available policies on CME, adopted by Canadian PMAs as of December 2015.
METHODS:
Policies were evaluated using an original scoring tool comprising 21 items, two questions about PMAs’ general and CME funding from industry, and three enforcement measures.
RESULTS:
We assessed 236 policies adopted by Canadian PMAs (range, 0 to 32). Medical associations received summative scores that ranged from 0% to 49.2% of the total possible points (maximum score = 63). Twenty-seven associations received an overall score of 0%. The highest mean scores were achieved in the areas of industry involvement in planning CME activities (mean: 1.1/3), presence of a review process for topics of CME activities (mean: 1.1/3), content review for balanced information (mean: 1.1/3), and responsibility of distribution of funds (mean: 1.0/3). The lowest mean scores were achieved in the areas of awards (mean: 0.0/3), industry personnel, representatives, and employees (mean: 0.1/3), distribution of industry-funded educational materials at CME activities (mean: 0.1/3), and distinction between marketing and educational materials (mean: 0.1/3).
CONCLUSION:
These results suggest that Canadian PMAs’ publicly available policies on industry involvement in CME are generally weak or non-existent; therefore, the accredited CME that is provided to Canadian physicians may be viewed as open to bias. We encourage all Canadian medical associations to strengthen their policies to avoid the potential for industry influence in CME.
Keywords
Introduction
Professional medical associations (PMAs) provide members with professional educational opportunities including accredited continuing medical education (CME) or continuing professional development (CPD); hereinafter, collectively referred to as CME. However, there is an ongoing debate about whether the CME that these organizations offer may be undermined because of a perception of bias due to either CME funding that they receive from and/or financial ties that organizations have with pharmaceutical and medical device companies, hereafter collectively referred to as the pharmaceutical industry. While some investigators are concerned about this bias [1–4], a systematic review commissioned by the Accreditation Council for Continuing Medical Education found no evidence of bias [5].
It is important for physicians to participate in CME to not only maintain their credentials, but also to keep informed of new pharmaceutical and non-pharmaceutical treatments. The integrity and credibility of CME provided by medical associations has been questioned because it has become so closely linked with the marketing initiatives of the pharmaceutical industry [3, 6–8]. Data from the United States (US) suggests that, in 2014, support from the pharmaceutical industry accounted for approximately 25% of total income reported by CME providers [9]. Although industry representatives maintain that the intent behind their funding of CME is motivated by the desire to provide up-to-date information to doctors, researchers independent from the pharmaceutical industry suggest that this financial support is used to advance sponsors’ marketing interests [3, 10, 11]. Funding for CME is generally considered by researchers to be part of the marketing budget, dedicated to producing sales, and they include it when reporting promotional expenses [12, 13]. Fugh-Berman and Hogenmiller argue that even when CME activities have not received pharmaceutical industry funding, speakers who are funded by industry can still be used [14].
Tools have been developed for evaluating the potential for bias within CME presentations but they do not evaluate the policies that medical associations have adopted to guide industry involvement prior to the CME event [15–17]. The purpose of this study is twofold: we present an original tool for evaluating policies adopted by PMAs concerning financial conflict of interest (FCOI) relationships and industry involvement in CME. We, then, use the tool to conduct a systematic evaluation of CME policies that have been adopted by Canadian PMAs.
Methods
Creation of the scoring system
The items included in the tool for evaluating the policies of the PMAs were compiled based on the works by Barnes and colleagues [15], Dyck and Kvern [16], Takhar and colleagues [17], Kassirer [2], and Rothman and colleagues [4].
Three experts (see Acknowledgements) independently reviewed both the list of items and the draft scoring system for face validity. The tool was modified based on their feedback regarding clarity and consistency between scores so that the range of scores for each item had comparable restrictiveness.
The two authors pilot tested and modified the items and the scoring system based on the policies of 10 Australian PMAs. Australian associations were deemed to be appropriate for the pilot test because the Australian medical system is broadly similar to that of Canada. Further refinements were made to the scoring tool in the process of the actual policy reviews.
The final scoring tool comprises 21 categories, two questions, and three enforcement measures. Each of the 21 categories is rated on a 4-point scale, where 0 = no policy found, 1 = weak or permissive policy, 2 = moderate policy, and 3 = strong or restrictive policy (Appendix 1). Therefore, the highest attainable score is 63, while the lowest possible score is 0. Across items in the scoring tool, a score of 3 indicates no pharmaceutical industry involvement and no financial ties with industry. A score of 2 indicates that, where there is industry involvement in planning or presenting CME programs, the PMA retains ultimate authority. A score of 1 indicates that the item was addressed in the policy, but that industry involvement was still permitted without clearly stating that the PMA retained ultimate authority over CME decisions. Scores for each PMA are expressed as percentage of the maximum possible score.
The two questions (Q1 and Q2) inquire about PMAs’ general and CME funding from industry. The three enforcement measures (EA, EB, and EC) seek to determine whether a party is clearly identified as being responsible for general oversight to ensure compliance, sanctions for noncompliance [18], and investigations into noncompliance (Appendix 1). The results of the questions and enforcement measures are represented as binary outcome measures (i.e., yes or no) and reported separately from the composite score for the 21 categories. We did not attempt to ascertain whether PMAs’ policies had been violated, nor did we measure the severity of the sanctions identified within policies.
One author initially scored policies for all of the PMAs and the second author independently conducted duplicate scoring for each fifth PMA policy. Results were compared and disagreements were resolved through discussion. Where disagreements revealed differences in how similar policies from other PMAs were interpreted these policies were also discussed.
Policy collection
We obtained a list of 58 PMAs from the Royal College of Physicians and Surgeons of Canada (RCPSC) website (http://www.royalcollege.ca/rcsite/resources/national-specialty-societies-e). We also included the College of Family Physicians of Canada (CFPC) and the RCPSC (hereinafter collectively included within the definition of PMAs). The RCPSC was included because many of the individual PMAs referenced its policies and because it also accredits CME. Similarly, the CFPC accredits CME for family physicians. Therefore, we searched the websites of 60 associations for publicly available English-language policies, guidelines, or interpretive documents (hereinafter collectively referred to as “policies”) specifically related to accredited CME activities. An example of an interpretive document is a conflict of interest disclosure form. We limited our search to publicly available policies because we felt that they need to be readily accessible in order to ensure public trust in the operation of these associations and so that doctors are able to assess how pharmaceutical industry involvement in CME is dealt with before they attend events and during the events themselves. In the absence of public disclosure there is also no way of assessing whether the policies are being adhered to.
When PMAs’ websites had search-bars, we used the search terms “policy”, “policies”, “accreditation”, “accredited”, “medical education”, “continuing medical education”, “CME”, and “continuing professional development”, “CPD” to locate the policies. When using the search bar did not return any results or in the absence of a search bar, we made an effort to manually search the association’s website to find policies.
When PMAs’ websites referred to external documents, but provided no link to them, we did not collect these documents. Additionally, when PMAs referred to general college websites, such as that of the RCPSC, but did not provide the link to a particular policy, we did not conduct a search of the external site. When PMAs provided documents from, or direct links to, industry codes (i.e., Rx&D Code of Conduct [19], MEDEC Code of Conduct [20]) we did not evaluate these documents because the PMAs cannot enforce or modify industry codes.
We recorded the titles of policies and the adoption or most recent review dates. If more than one policy was included within a document and the policies had different dates, the most recent date within the overall document was considered to apply to all contained policies. A primary collection of policies was conducted from June 30, 2015 to July 4, 2015 with a secondary collection from December 1, 2015 to December 7, 2015. At this latter time, we also recorded whether associations’ websites identified having received pharmaceutical industry sponsorship within the last five years for overall societal activities and for its accredited CME. While this study was ongoing the RCPSC, CFPC and the Collège des Médecins du Québec (CMQ), hereafter referred to as the coalition, announced a new set of national standards that will be officially launched on January 1, 2018 and we evaluated this policy [21].
When more than one policy per society addressed an item in the scoring tool, the highest score was taken for final calculation of the association’s score for that item.
We report overall scores for each association and the mean score for each of the 21 items.
As this study only involved the evaluation of publicly available policies ethics approval was not required.
Results
We assessed 236 policies, which were collectively adopted by 60 Canadian PMAs (range, 0 to 32 policies per association) and the coalition. Eight documents were inaccessible (“page not found” or “link broken”: 7 documents, password login required to view policy: 1 document) (Appendix 2).
The dates of 112 documents were not provided. The remaining 124 policies ranged in date from 2004 to 2016. Although the joint policy from the coalition will not come into effect until 2018 it was drafted in 2016. One document was more than 10 years old, while 69 were adopted within four years of March 2016 (Appendix 2).
The Canadian Medical Association’s policy on physicians’ interactions with industry [22] was formally adopted by 22 out of 60 Canadian medical associations, while 30 associations plus the coalition reference it in their own policies. For the RCPSC guidelines, the corresponding numbers are 15 and 20, respectively.
Twenty-seven associations received an overall score of 0/63 (0%), indicating that these associations either had no publicly available policies or that their policies did not address the items in the scoring tool. The remaining 34 medical associations received scores that ranged from 9/63 (14.3%) to 31/63 (49.2%) (median: 23.0 (37.7%), interquartile range [IQR]: 21 to 24.0 (34.4% to 39.3%)). The joint policy from the coalition was the only policy to receive a score of 3 for any item (satellite symposia), which represents the greatest restrictiveness (Appendix 3).
The highest mean scores (1.1/3) were achieved in the areas of pharmaceutical industry involvement in planning CME activities, presence of a review process for topics of CME activities, content review for balanced information, and responsibility of distribution of funds (mean: 1.0/3). The lowest mean scores were achieved in the areas of awards (0.0/3), industry personnel, representatives, and employees, distribution of industry-funded educational materials at CME activities, and distinction between marketing and educational materials (0.1/3) (Appendix 3; Table 1). None of the 21 items were addressed by all policies. Awards was not addressed by any association, while the most frequently addressed item was presence of a review process for topics of CME activities (34 of 60 associations plus the coalition) (Table 1).
Scoring tool items and summary of results by item
Scoring tool items and summary of results by item
Twenty-three (38%) PMAs publicly disclosed that they accepted industry sponsorship (Q1), while 49 (82%) PMAs received industry sponsorship specifically for CME activities (Q2). The policies adopted by 34 of the 60 medical associations plus the policy from the coalition identified a party responsible for oversight to ensure compliance (EA) (Table 2), e.g., the “planning committee” or “chair of the planning committee” [23]. Eighteen of the 60 medical associations plus the coalition identified sanctions for noncompliance with the policies, e.g., an RCPSC COI disclosure form stated that “Failure to disclose or false disclosure may require the Planning Committee to replace the speaker” [23]. The College of Family Physicians of Canada adopted the most extensive description of action in cases of CFPC policy violation [24]. None of the medical associations stated within their policies that the results of the investigations into noncompliance would be made accessible on the society’s website.
Summary of results by professional medical association
a“Industry” refers to pharmaceutical and medical device companies and other companies directly contracted by them.
The 60 Canadian professional medical associations plus the coalition received scores that ranged from 0% to 49.2% of the maximum possible score. Approximately half of the medical associations received scores of 16/63 (25.4%) or lower. The remaining 30 medical associations received scores between 17/63 (27.0%) and 31/63 (49.2%). Out of the 124 policies where dates were provided, 69 were developed within the previous 4 years. Therefore, in these cases we do not feel that the poor scores reflect older policies that may have been adopted before FCOI became a concern.
In general, the items that had the highest mean scores received scores of 2/3 indicating that the medical associations retained complete control over the planning and topics of CME activities and were responsible for ensuring the validity and objectivity of educational material. The item concerning responsibility for distribution of funds usually received a score of 2/3 indicating that PMAs’ CME committees held the responsibility for distributing grants from industry. The RCPSC has stated that companies that provide educational grants possess “ ... legal obligations to ensure any financial support provided is directed to a specific event or activity” [25].
The lowest scores were received in the areas of awards (mean: 0.0/3), industry personnel, representatives, and employees, distribution of industry-funded educational materials at CME activities, and distinction between marketing and educational materials (mean: 0.1/3). Only 13 out of 60 medical associations plus the coalition addressed the item regarding funding for CME activities in their policies, mean score of 0.3/3, indicating that medical associations tend to permit one or more pharmaceutical industry sponsors to provide funding for CME events.
Scores of 1/3 indicate permissiveness and tend to have an effect which is equal to that of a non-existent policy. However, it was important to distinguish between areas where even permissive policies existed and where policies were non-existent. This distinction allows CME participants and providers to identify the areas that have been addressed, even if permissively, as opposed to completely left out.
Given the number of medical associations that formally include or reference the guidelines from either the Canadian Medical Association or the Royal College of Physicians and Surgeons of Canada, if one or both of these associations changed their guidelines, those changes would have a wide ranging effect. A similar effect might be seen depending on how the medical associations deal with the new policy from the coalition once that policy becomes effective in 2018.
Critics of conflict of interest regulation might argue that adopting and enforcing stringent policies assumes wrongdoing and attaches blame to the individual or institution engaging in the financial relationship [26]. However, and importantly, this criticism may not appreciate the degree to which institutional FCOI relationships could threaten not only the trust that physicians and patients have in the roles of associations [26], but also the independence of the content included within CME programs [27].
International literature on institutional financial relationships between PMAs and the pharmaceutical industry supports the need for critical analysis of their policies on industry involvement and influence in CME activities. Cosgrove and Bursztajn argue that if CME activities are sponsored by industry, the completeness and accuracy of the educational information provided may be not only incomplete, but also biased [28]. They recommend a system of checks and balances and clear enforceable policies to safeguard against the potential for industry influence in the CME activities in which physicians participate.
Not all off-label mentions in CME events are necessarily inappropriate or commercially driven, but off-label prescribing is encouraged through teaching and research activities, including CME [29]. In over half of the cases in the study by Kesselheim and colleagues, speakers chosen for CME were known to promote off-label medication use. Steinman and colleagues found that drug companies use CME activities as a venue for direct-to-physician promotion to convince both current prescribers and non-prescribers to increase new prescriptions [30]. Off-label prescribing can be appropriate, but in most cases there is little scientific evidence to justify it [31].
It is possible for PMAs to reduce their financial dependence on, and relationships with, industry. At its annual meeting and CME conferences, the North American Spine Society prohibits company logos on promotional items and does not sell lists of CME participants to companies in order to prevent “robo calls” to participants’ hotel rooms at CME events. It further rejects funding for meals and snacks at its CME events. To account for the decrease in industry funding for CME, annual membership and meeting registration fees and fees charged for exhibit hall booths were increased modestly, although some commentators do not view this as an acceptable alternative [10]. Despite these modest increases, physician membership has also increased [32]. The Oregon Academy of Family Physicians no longer accepts any grants, restricted or unrestricted, for its CME events or allows drug companies to have booths in its exhibit hall during conferences [33]. In response to the increasing awareness and concern over industry’s influence via financial relationships, over 100 large medical institutions in the US severed their financial ties with industry [34].
In Canada, CME programs for physicians receive a substantial portion of funding from pharmaceutical and medical device companies, although it is widely accepted that industry involvement in education influences physicians’ prescribing choices [8, 35]. It is unlikely that companies would donate substantial funds without any expectation of return from increased sales [8].
Limitations
Although we attempted to make the scoring tool as universally applicable as possible, some associations’ policies and documents included important areas for which the scoring tool did not account, for example peer selling and FCOI of CME moderators or facilitators. We view our tool as a living document that needs further study and refinement and in this process these additional items and other areas should be addressed.
We attempted to do a thorough search of each association but it is possible that the key words that we used and our manual searches missed relevant policies.
Where policies did not directly reflect the content of the scoring system, we had to determine if their contents complied with the spirit of the scoring system and, therefore, our interpretation of the policy may have had a subjective element. Importantly, the overall score for each policy for a single item may have been based on more than one phrase in one or more policies of a PMA. Although the scoring tool separated FCOI into many discrete activities, associations’ policies were not necessarily structured in the same way. Therefore, a clause in a policy could have been relevant to more than one item in the tool and, as a result, would have been scored under both items.
We did not contact medical associations to see if they were in agreement with our assessments. We also evaluated policies without analyzing any CME events sponsored by these associations. Despite permissive policies, CME events accredited by PMAs might still be free of possible industry bias. A comparison of policies and practice is an area for future research in order to determine the extent to which policies are implemented and enforced.
Finally, although we attempted to ensure that our tool had face validity by having it peer reviewed we recognize that there will always be an element of subjectivity in any such tool.
Conclusion
We conducted a comprehensive evaluation of the policies on CME activities and industry involvement adopted by 60 Canadian medical associations plus the new policy from the coalition. We found the publicly available policies to be generally weak or non-existent. This weakness was coupled with the majority of associations having disclosed industry sponsorship for CME activities in the last five years. The next step is to evaluate whether the policies in place lead to a bias in the topics and content of CME and if these biases exist whether they are due to weaknesses in the policies.
Should there be an association between deficiencies in the policies and biases then in order to avoid institutional FCOI relationships with industry, PMAs should avoid seeking and accepting industry funding for CME activities. Alternative mechanisms for financing CME activities may include modestly increasing membership dues and registration costs [36]. Another approach might include lobbying provinces to reimburse physicians for attending CME events and some provinces have already taken this initiative [37]. PMAs could also lessen possible bias by only accepting anonymous industry sponsorship, a move recommended by a recent report from the College of Family Physicians [38].
The Canadian PMAs ought to take a leadership position on behalf of their physician members and the patients that they serve when it comes to acceptable conduct in the context of FCOI relationships [36]. We urge the medical associations that have not adopted any policies to, at the very least, adopt the policies from the Royal College of Physicians and Surgeons of Canada and the Canadian Medical Association or the new policy from the coalition. We also encourage Canadian PMAs to review and strengthen their policies to protect the integrity of the education that Canadian physicians are receiving and applying in the treatment of their patients.
Conflict of interest
The authors have no conflict of interest to report.
Footnotes
Acknowledgments
We thank Drs. David Menkes, Barbara Mintzes, and Ray Moynihan for their comments on an earlier draft of the scoring tool. We also thank Drs. Marc-André Gagnon and Harriet Rosenberg for their comments on an earlier version of the manuscript.
